corruption is regarded as a more serious
crime than simple dishonesty and the international concern about this kind of crime and the difficulty of investigating this offence may justify exceptional
measures.

present law is dependent on a distinction between public and non-public bodies.

The distinction between public and non-public bodies causes difficulty because of uncertainty as to what constitutes a public body. Many former public bodies have now been privatised, and it is uncertain which of them, if any, can still be regarded as public bodies.

For example, it is uncertain whether certain categories of individuals, such as judges, fall within the definition of an agent. It appears that the
1906 Act, unlike the 1889 Act, does not extend to those who accept bribes before or after the currency of their agency, or to third party recipients.